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Our understanding is that from its inception the willingness to share information has been a precondition of membership of a local Connexions partnership, with the aim of identifying individuals deemed 'at risk of social exclusion'. We have not yet found the criteria to be employed when such a subjective and potentially pejorative judgment is made.

Further, even if it is stated that the existence of the power to share information does not mean that it will be used, this is a guarantee that only binds the present government, if it binds them at all. We have heard too often from the DfES that it "will not use" a power contained in legislation, yet as recently as Monday 18th November, John Denham asserted to the Joint Committee on Human Rights that the Government does not enact legislation that it does not intend to use.

You state that information is only shared "with the express consent of the young person". This is simply not correct for those young people specifically targeted by Connexions, who can be referred to the Service without their knowledge, let alone consent. It is not even an accurate statement with regard to those who opt to use the services offered, as we have pointed out in our website. The young person is asked to consent to the general principle of data-sharing rather than each specific instance; this would ordinarily be a breach of data protection principles. Mr Stephen Timms has confirmed in a parliamentary written answer that a young person cannot control access to data once consent has been given. This makes it impossible for young people to retain the power to decide if there are particular agencies with whom they do not wish to become involved. Anyone seeking to engage with any of the agencies that are partners in Connexions has to engage with all or none.

It is hard to see how such a lack of respect for integrity and privacy can empower vulnerable young people; if they were to be aware of what they were entering into it is perhaps likely that they would choose not to engage at all. We are concerned that the realisation of this very point has driven the way in which the scheme has been developed. When young people are asked for their consent, where are the guidelines to guarantee that they will have understood the import of their decision; that all purposes for which their data is being collected will have been fully explained to them and that they have been encouraged to discuss their involvement with a parent or trusted adult before the giving of such blanket consent? Despite having asked on several occasions, we still do not know how long the Connexions Service National Unit intends to hold individual information about young people.

With regard to the consent to be obtained from young people, there appears to be some confusion in the minds of the DfES about the concept of parental responsibility. Indeed, the role of parents is reduced to that of a potentially "useful resource". Parents are legally and, as the Government reminds us quite rightly, morally responsible for their children. There is a raft of sanctions which enforce their duty. With regard to education, s7 Education Act 1996 makes the position quite clear: the primary responsibility for the efficient education of children and young people is the legal duty of their parents. The premise behind Connexions is the desire to remove "barriers to learning", it is thus an educational process and as such one in which parents must be fully involved. It is therefore wrong in our view that a young person is as a matter of course approached without any intention of contacting his/her parents, who are thus excluded from the Connexions process. This fundamentally undermines the role of the family and is in breach of several important principles enunciated in the Convention on the Rights of the Child.

The obtaining of information from young people, and the storage and circulation or availability of it, raise not only issues for that young person but also for their family, given that it is a fundamental principle of partners to the Connexions service that they must be prepared to share data. Confidentiality cannot exist in such a scheme. We should be interested to know what mechanisms exist for ensuring the consent of siblings and parents of a young person to the storage and sharing of their sensitive personal information, obtained in their absence, and for ensuring the accuracy of such data.

What arrangements exist to ensure that all those who might have access to this information have received a training sufficient to be able to understand the import of all that they enquire about? We appreciate that an aim of the Connexions service is to provide help to vulnerable young people; it is a worthwhile aim only if it is to be executed by those with an appropriate level of training and experience. We have consulted experts in mental health and child psychiatry and share their concerns about the extreme sensitivity of the issues that are required to be explored by the APIR document.

We would suggest that the skills of an experienced social worker are especially required when dealing with vulnerable young people, rather than the inevitably limited skills of a personal adviser who has undergone the equivalent of 17 days' training.

It is our belief that the Connexions scheme was brought in with little or no thought to the considerable and complex issues of confidentiality which surround it. We are also driven to the conclusion that there is all too clearly another agenda which requires the extensive collection and assembly of data at a national level. Whether that be for surveillance ("tracking") or for commercial interests such as the consumer profiles obtained, it is being carried out without there having been a full debate in the public arena about its consequences. This is compounded by the fact that the Government is fully aware of the objections expressed by the adult population for a national identity system. In our experience, those who learn of the data collection and storage aspects of Connexions are equally appalled and concerned at the undoubted intrusion into individual personal privacy. Disregarding these objections when considering the rights of children and young people who have no voice for themselves seems to us to be another example of the lack of real commitment by the Government to the Convention on the Rights of the Child.

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